Evaluating Your Data Deletion Strategy

If data is not in your possession, it cannot be stolen, breached, or used improperly. So, a proper data deletion strategy is crucial to successfully reducing risk of exposure to data misuse or involvement by bad actors.

Remember, deletion means:

• physically or logically destroying identifiable user data so that it cannot be recovered
• anonymizing data so it cannot reasonably be re-identified by anyone at your company or anywhere else, even if it becomes publicly disclosed

Use this assessment to evaluate your data deletion process and make a plan to improve your data deletion practices. Read the following actions and select the option that best describes your data deletion strategy. If neither option applies to your organization, do not select a box and move on to the next.

Actions

You tag user records with a machine-readable tag like “to_be_deleted”, indicating that the record for this specific customer is to be deleted.

1. Option 1: We tag customer records for deletion, but the process is manual. (1 point)
2. Option 2: We tag customer records for deletion at scale. (2 points)

You can identify and delete all notes related to a user requesting that their data be deleted.

1. Option 1: It is a part of our deletion process to manually search for and delete any notes related to a user who has requested their data be deleted. (1 point)
2. Option 2: We locate and delete all notes related to user records automatically and at scale. (2 points)

You can delete all third-party identities, corresponding identity graphs, and any data connected to cookies for those identities (e.g., Facebook, Google+).

1. Option 1: We manually check for and delete third-party identities associated with user records to be deleted. (1 point)
2. Option 2: Complete identity deletion is automated, including all activity data. (2 points)

You can delete any alternate email addresses associated with the user record.

1. Option 1: We check for and delete secondary or alternate email addresses. (1 point)
2. Option 2: Alternate email addresses tied to a user record are automatically deleted. (2 points)

You can delete all behavioral and inferred data related to a user requesting that their data be deleted.

1. Option 1: We have automated the identification and deletion of either behavioral OR inferred data, but not both. (1 point)
2. Option 2: We can delete behavioral and inferred data, but the process is manual. (1 point)
3. Option 3: We delete all behavioral and inferred data automatically and at scale. (2 points)

Customer payment profiles are deleted.

1. Option 1: We manually delete payment profiles for customers who request data deletion. (1 point)
2. Option 2: Payment profiles are automatically deleted for customers who request deletion. (2 points)

Customers requesting deletion are unsubscribed from any email lists.

1. Option 1: Deleted customers have to be manually unsubscribed from email lists. (1 point)
2. Option 2: Deleted customers are automatically unsubscribed from email lists. (2 points)

You have a process for identifying and blocking deletion when necessary.

1. Option 1: We do not currently have this process in place. (1 point)
2. Option 2: We currently have this process in place. (2 points)

You have a process for confirming that user records are completely, and successfully, deleted.

1. Option 1: We do not currently have a process in place to confirm user records are completely and successfully deleted. (1 point)
2. Option 2: We currently have a process in place to ensure complete and successful deletion of user data. (2 points)

Scoring